We collect, use, and/or otherwise process certain personal information about you. When we do so we are subject to various laws, including in the United States, the European Union, and United Kingdom. The following chart summarizes how we may be referred to concerning our personal information practices under various privacy laws:
|The General Data Protection Regulation (EU) 2016/679||“GDPR”||“Controller”|
|California Consumer Privacy Act of 2018 (Cal. Civ. Code § 1798.100)||“CCPA”||“Business”|
|Virginia Consumer Data Protection Act (Va. Code § 59.1-575)||“VCDPA”||“Controller”|
|Colorado Privacy Act (Colo. Rev. Stat. § 6-1-1301)||“CPA”||“Controller”|
|Connecticut Act Concerning Personal Data Privacy and Online Monitoring (Connecticut General Statutes 743dd)||“CPDPA”||“Controller”|
|Utah Consumer Privacy Act (S.B. 227)||“UCPA”||“Controller”|
1. Key Terms
|We, us, our||enosix, Inc.|
|Personal information||Any information that identifies, relates to, describes, is linked or could be reasonably linked, directly or indirectly, to an identified or identifiable natural person or household.|
|Sensitive data||A category of personal information that includes Social security number, driver’s license number, state identification card, or passport number; account log-ins, financial accounts, debit or credit card numbers in combination with a security or access code, password, or other credentials; precise geo-location; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of mail, email or text messages; genetic or biometric data; mental or physical health diagnosis, sexual orientation; or personal data from a known child.|
2. Personal Information We Collect About You
We may collect, use, and share in accordance with applicable privacy law the following categories of personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics or samples (such as breath, blood, or urine), or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing provide products and/or services to you.
3. Notice Concerning Sensitive Data
We may collect sensitive data about you or your household. We take specific business practices to limit the use and disclosure of sensitive personal data, such as:
- Just-in-time notices at the collection of sensitive data
- Requiring your express consent for the collection of sensitive data
- Aggregating and/or de-identifying the sensitive data.
You may direct us to use this sensitive data only for purposes necessary to perform the service or provide the goods that you request from us, with the exception of the following:
- Collection or processing of sensitive personal data for security purposes;
- Maintaining/servicing accounts; and
- Undertaking activities to verify/maintain the quality of a service
You may also opt out of the use of sensitive data by emailing us at email@example.com.
4. Children Under the Age of 18
This Website is marketed for, and directed to, purchase by adults or with the consent of adults. Individuals under the age of 18 (or the age of majority in their jurisdiction of residence, if different) are not permitted to use the Website without the supervision of a parent or legal guardian.
We do not knowingly collect or solicit personal information from anyone who we know to be under the age of 18, or knowingly allow such persons to use the Website. Should we learn that someone under the age of 18 has personal information through the Website without the verified supervision of a parent or guardian, we will remove that personal information as soon as possible.
If you are under the age of 18, you should not use our Website, register on our Website, make any purchases through our Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use without the verified supervision of a parent or guardian. To the extent possible, any personal information from anyone who we know to be under the age of 18 will be destroyed.
If you believe we might have any information from or about a child under 18, please contact us at firstname.lastname@example.org.
If you are a child under the age of 18, you may opt-in to allow us to sell your personal information with the permission of your parent or guardian by emailing us at email@example.com.
5. How Personal Information is Collected
We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:
- Directly from you when you provide it to us, such as:
- Information that you provide by filling in forms.
- This includes:
- Information provided at the time of registering for services or programs on our Website,
- Subscribing to our mailing list or other services,
- Requesting further services.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Information collected through email, text, or other electronic messages.
- This includes:
- Through your online activity, such as:
- Browsing our Website,
- Interacting with Website features such as forms, and/or
- Clicking on our advertisements.
- We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Information from tracking technologies, such as browser cookies, flash cookies, or web beacons.
- Details of website visits, such as traffic data, location data, logs, resources used to access the website.
- Information about the user’s computer and internet connection, such as IP address, operating system, or browser type.
- From third parties, such as advertisers, ad networks and servers, content providers, application providers or data brokers.
- Via our IT systems.
- Information that you provide by filling in forms.
6. Cookies & Other Tracking Technology
A cookie is a small file containing a string of characters that may be sent to your web browser when you visit a website. Cookies might be used for the following purposes: (1) to enable certain functions; (2) to provide analytics; (3) to store your preferences; and (4) to enable ad delivery and behavioral advertising.
Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire at a later time. Cookies placed by the website you’re visiting are sometimes called “first party cookies,” while cookies placed by other companies are sometimes called “third party cookies.”
B. Third-Party Service Providers and Additional Technology
We sometimes utilize third-party service providers to help us track the activity within the Website. Our third-party service providers include the following:
- Salesforce Pardot (https://www.salesforce.com/company/privacy/)
- 6Sense (https://6sense.com/privacy-policy/)
- Google Ad Network (https://policies.google.com/privacy)
- Kinsta (https://kinsta.com/legal/privacy-policy/)
- WordPress (https://wordpress.org/about/privacy/)
- Wistia (https://wistia.com/privacy)
- HotJar (https://www.hotjar.com/legal/policies/privacy/)
- LinkedIn Sales Navigator and LinkedIn Ads (https://www.linkedin.com/legal/privacy-policy)
- ZoomInfo (https://www.zoominfo.com/about-zoominfo/privacy-policy)
- Remarketing with Google Analytics
- Google Display Network Impression Reporting
- DoubleClick Campaign Manager integration Google Analytics Demographics and Interest Reporting
Third-party vendors, including Google, show our ads across the internet. We use ad-tracking along with third-party vendors. These use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie). Together, these cookies report if you have seen our ads (ad impressions) and how you have interacted with our ads and ad services. We want this information so we can make sure our advertising that you see is relevant to you.
We may also use additional technologies to help track user activities and preferences. The following Information may automatically be received and/or collected from you through the Site: IP address, browser type, browser language, internet service provider (ISP), resource requested, date and time of resource request, and HTTP referring resource (if provided by the browser), operating system, and/or clickstream data. We aggregate this data, and may combine this data with other information we collect about you to better understand how visitors use our site, improving user experience, and to help manage, maintain, and report on use of our website. We also store IP addresses for fraud detection and prevention purposes. This Website does not alter their practices when it receives Do-Not-Track (“DNT”) signals. To find out more about DNT, you may wish to visit the following third-party website: www.allaboutdnt.com.
7. Notice Regarding Targeted (Behavioral) Advertising
We partner with third parties such as ad networks and other advertising companies to display advertising on our Website and manage our advertising on other websites. As described above, our third party partners may use technologies such as cookies to gather information about your activities on our Website and other websites (such as web pages you visit and your interaction with our advertising and other communications) in order to make predictions about your preferences and provide you with tailored advertising across the Internet based upon your browsing activities and interests. This information may also be used to evaluate the effectiveness of our online advertising campaigns. Our use of personal information for cross-contextual behavioral advertising purposes constitutes the “sharing” of personal information under the CCPA.
Some of the advertisers and service providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioural Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps.
Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices.
If you are a resident of California, Virginia, Colorado, Connecticut, or Utah, you have the right to opt out of our use of your personal information for the purpose of serving you interest-based ads. Residents of these states may opt-out by clicking the link titled “Do Not Share My Personal Information” in the footer of this page and following the instructions.
To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again. Please note this does not opt you out of being served advertisements. You will continue to receive generic advertisements from us, but the ads will not be targeted based on behavioral information about you and may therefore be less relevant to you and your interests.
We may also partner with third-party service providers to engage in “profiling” which is defined in the VCPA, CPA, and CPDPA as “any form of automated processing performed on personal data to evaluate, analyze, or predict personal aspects related to an identified or identifiable natural person’s economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.” Residents of Virginia, Colorado, and Connecticut may opt out of processing of your personal information for purposes of profiling by emailing us at firstname.lastname@example.org.
8. Social Media and Third-Party Links
9. Why We Use Personal Information
We use your personal information for a number of reasons, including the following:
- To comply with our legal and regulatory obligations;
- To present the Website and its contents to you;
- To provide you with information or services that you request from us;
- To fulfill any other purpose for which you provide it;
- To take steps at your request before entering into a contract;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- To contact you about goods or services that may be of interest to you;
- To display advertisements to your advertisers’ target audience;
- For our legitimate interests or those of a third party; or
- In any other way we may describe when you provide the information or for any other purpose with your consent or to comply with applicable law.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide products and/or services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|To prevent and detect fraud against you or our organization||For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you|
|To display advertisements to our advertisers’ target audiences.||For our legitimate interests or those of a third party, i.e., to efficiently and accurately advertise to you so we can deliver the best service for you at the best price.|
|Processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator||To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies||To comply with our legal and regulatory obligations|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorized access and modifications to systems||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services to existing and former customers, third parties who have previously expressed an interest in our services and/or third parties with whom we have had no previous dealings.||For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers|
|External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts||For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
To comply with our legal and regulatory obligations
10. Who We Share Your Personal Information With
We routinely share personal information with:
- Contractors, vendors, service providers, and financial service providers we use to help deliver our products and/or services to you;
- Other third parties we use to help us run our business, such as our website host;
- Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
- Our attorneys and financial advisors.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We may provide aggregated, de-identified or other information that is not personally identifiable to third parties for any purpose that complies with applicable law with or without your consent.
11. Notice Regarding the Sale of Your Personal Information or Use for a Business Purpose
In the preceding 12 months, we have not sold your personal information to third parties.
12. Promotional & Marketing Communications
We may use your personal information to send you updates (by email, text message, telephone and/or social media post) about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in processing your personal information for promotional purposes (see above “Why We Use Your Personal Information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, such as for Canadian residents, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time by contacting us at email@example.com or using the “unsubscribe” link in emails.
From time to time, we may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
13. How Long Your Personal Information Will Be Kept
We will keep your personal information for as long as necessary to fulfill the purposes we collected it for and in accordance with any applicable laws. We will retain and use personal information as long as you have an account with us or we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly; or
- To keep records required by law.
Under some circumstances, we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.
14. Keeping Your Personal Information Secure
To protect your personal information in our custody or control from theft, unauthorized access, use, modification and disclosure, and to maintain its accuracy and integrity, we have implemented reasonable technical, physical and administrative security measures. These measures include:
- Stored on secure servers behind firewalls;
- Encrypted payment transactions using SSL or other technology;
- De-identifying or aggregating the information;
- Other measures to secure the personal information from accidental loss and from unauthorized access, use, alteration, and disclosures
Although we have implemented reasonable safeguards, please note that no electronic transmission of information can be guaranteed to be entirely secure. You acknowledge and agree that we are not responsible for the theft, destruction, or inadvertent disclosure of your personal information. In the unfortunate event that your personal information is compromised, we may notify you by e-mail (at our sole and absolute discretion) to the last e-mail address you have provided us in the most expedient time reasonable under the circumstances; provided, however, delays in notification may occur while we take necessary measures to determine the scope of the breach and restore reasonable integrity to the system as well as for the legitimate needs of law enforcement if notification would impede a criminal investigation.
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”). Some of these third parties may be based outside the United States. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information”.
15. Transferring Your Personal Information
We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this police.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable state privacy legislation.
This Website is hosted in the United States. This Website may function in countries other than the United States. If you use the Website from outside the United States and submit your personal information or engage with the Website, you explicitly consent to the transfer, storage, or processing of your personal information in a country other than the United States where laws regarding processing of personal information may differ from the laws of other countries. You are responsible for compliance with the laws of the jurisdiction in which you choose to use the Website.
By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.
16. Notice to California Residents
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, please review our Privacy Notice for California Residents located here.
California’s “Shine the Light” law (Civil Code § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org.
17. Notice to Certain State Residents
If you are a resident of the states of Virginia, Colorado, Utah, or Connecticut, your state may have provided you with additional rights regarding our use of your personal information. To learn more about these rights, please review our Privacy Notice for Certain State Residents located here.
18. Notice to International Residents
European / United Kingdom Rights Under the GDPR
If you are a citizen of the United Kingdom (“UK”) or the European Economic Area (“EEA”), in addition to the rights described within, you are also entitled to the following rights under the General Data Protection Regulation:
|Right to Access||The right to be provided with a copy of your personal information (the right of access)|
|Right to Rectification||The right to require us to correct any mistakes in your personal information|
|Right to be Forgotten||The right to require us to delete your personal information—in certain situations|
|Right to Restriction of Processing||The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data|
|Right to Data Portability||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|Right to Object||The right to object:
– at any time to your personal information being processed for direct marketing (including profiling);
– in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
|Right Not to be Subject to Automated Individual Decision-Making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
We hope that we can resolve any query or concern you raise about our use of your information.
How to File a GDPR Complaint. The GDPR also gives you right to lodge a complaint with a supervisory authority, in the European Union (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws occurred. For contact details of your local Data Protection Authority, please see: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
20. How to Contact Us
- Sending us physical mail at: 250 E Fifth Street, Suite 1500, Cincinnati, Ohio 45202
- Emailing us at: email@example.com
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy, please contact our Privacy Officer using the contact information listed above.
21. Do You Need Extra Help?
If you would like this notice in another format (for example, audio, large print, or braille) please contact us via the methods above in “How to Contact Us.”